PRIVACY COMMITMENT: This Privacy Policy ("Policy") explains how CLICK SMART DIGITAL PRIVATE LIMITED ("Company," "we," "us," or "our") collects, uses, processes, and protects your personal information when you use our Tatkal Rummy platform, mobile application, and related services ("Services"). We are committed to maintaining the highest standards of data privacy and security in accordance with applicable laws including the Information Technology Act, 2000, and the Digital Personal Data Protection Act, 2023.

1. Information We Collect

• Personal Information:
  • Full name, date of birth, and age verification details
  • Email address and mobile phone number
  • Residential address and identity verification documents
  • Government-issued identification (Aadhaar, PAN card, etc.)
  • Basic account settings information
  • Profile photographs and selfies for verification
• Gaming Data:
  • Game play history, statistics, and performance metrics
  • Activity records, in-app requests, and game coin progress
  • Chat messages and communications within the platform
  • Tournament participation and ranking information
• Technical Information:
  • Device information (model, operating system, unique identifiers)
  • IP address, location data, and network information
  • Browser type, version, and usage patterns
  • Application performance data and crash reports
• Behavioral Data:
  • Website and app navigation patterns
  • Feature usage and preference settings
  • Response to promotional materials and communications
  • Support interactions and feedback provided

2. How We Collect Information

• Direct Collection: Information you provide during registration, verification, or while using our services.
• Automatic Collection: Data collected through cookies, analytics tools, and tracking technologies.
• Third-Party Sources: Information from service providers (e.g., verification services) and social media platforms.
• Communication Monitoring: Customer support interactions, live chat sessions, and phone calls may be recorded.

3. Purpose and Legal Basis for Data Processing

• Service Provision:
  • Creating and managing your gaming account
  • Handling in-app requests and feature operations
  • Facilitating gameplay and tournament participation
  • Providing customer support and resolving disputes
• Legal Compliance:
  • Verifying identity and age to prevent underage gaming
  • Conducting (Know Your Customer) procedures
  • Complying with anti-money laundering regulations
  • Maintaining records as required by gaming authorities
• Security and Fraud Prevention:
  • Detecting and preventing fraudulent activities
  • Monitoring for responsible gaming violations
  • Protecting platform integrity and fair play
  • Investigating suspicious activities or behavior
• Business Operations:
  • Improving our services and user experience
  • Conducting analytics and research
  • Marketing and promotional communications
  • Developing new features and offerings

4. Data Sharing and Disclosure

• Service Providers: We share data with trusted third-party providers who assist in:
  • Platform operation support services
  • Identity verification and fraud prevention
  • Customer support and communication
  • Analytics, marketing, and technical services
• Legal Requirements: We may disclose information when required by:
  • Court orders, legal processes, or government requests
  • Compliance with applicable laws and regulations
  • Protection of our rights, property, or safety
  • Investigation of suspected illegal activities
• Business Transfers: In case of merger, acquisition, or sale of assets, user data may be transferred to the acquiring entity.
• Consent-Based Sharing: We may share information with your explicit consent for specific purposes.

5. Data Security Measures

• Encryption: All sensitive data is encrypted both in transit and at rest using industry-standard protocols.
• Access Controls: Strict access controls ensure only authorized personnel can access personal data.
• Regular Audits: We conduct regular security audits and vulnerability assessments.
• Secure Infrastructure: Our servers are hosted in secure data centers with physical and digital protection.
• Employee Training: All staff receive training on data protection and privacy requirements.
• Incident Response: We have procedures in place to respond quickly to security incidents.

6. Cookies and Tracking Technologies

• Essential Cookies: Required for basic platform functionality and security.
• Performance Cookies: Help us understand how users interact with our platform.
• Functional Cookies: Remember your preferences and settings.
• Advertising Cookies: Used to deliver relevant advertisements and measure campaign effectiveness.
• Cookie Management: You can control cookie settings through your browser preferences.

7. Data Retention and Deletion

• Retention Periods:
  • Account data: Retained while account is active plus 7 years after closure
  • Relevant activity records: Maintained for up to 10 years for legal compliance
  • Game play data: Retained for 5 years for analysis and dispute resolution
  • Marketing data: Retained until consent is withdrawn
• Secure Deletion: Data is securely deleted using industry-standard methods when retention periods expire.
• Backup Data: Backup systems may retain data for additional periods for disaster recovery purposes.

8. Your Privacy Rights

• Access Right: Request a copy of all personal data we hold about you.
• Correction Right: Request correction of inaccurate or incomplete personal data.
• Deletion Right: Request deletion of your personal data (subject to legal retention requirements).
• Portability Right: Request transfer of your data to another service provider.
• Objection Right: Object to processing of your data for marketing purposes.
• Consent Withdrawal: Withdraw consent for specific data processing activities.
• Complaint Right: Lodge complaints with relevant data protection authorities.

9. International Data Transfers

• Transfer Basis: Data may be transferred to countries with adequate protection levels or under appropriate safeguards.
• Safeguards: We implement contractual clauses and certification schemes to protect transferred data.
• Third-Country Processing: Some service providers may process data outside India under strict privacy agreements.

10. Children's Privacy

• Age Restriction: Our services are not intended for individuals under 18 years of age.
• Verification: We implement age verification measures to prevent underage registration.
• Data Deletion: If we discover that a child has provided personal information, we will delete it immediately.
• Parental Controls: Parents can contact us to review or delete any information about their children.

11. Marketing Communications

• Consent-Based: Marketing communications are sent only with your explicit consent.
• Opt-Out Options: You can unsubscribe from marketing emails at any time.
• Preference Management: Control your communication preferences through your account settings.
• Personalization: We may personalize marketing content based on your gaming preferences and behavior.

12. Policy Updates and Changes

• Regular Reviews: This policy is reviewed and updated regularly to reflect changes in law and practice.
• Notification: Material changes will be communicated via email and platform notifications.
• Continued Use: Continued use of our services after policy updates constitutes acceptance of changes.
• Version Control: We maintain previous versions of this policy for reference.

13. Contact Information and Data Protection Officer

• Data Protection Officer: business@clicksmarttechltd.com
• Customer Support: Available 24/7 for privacy-related inquiries
• Postal Address: 1B01, A-27A, Sector 16, Noida, Gautambuddha Nagar, Uttar Pradesh, 201301
• Response Time: We respond to privacy requests within 30 days of receipt